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Chairman Walden and Representative Pallone:

As the House Energy and Commerce Committee considers legislation regarding the reauthorization of Medicare Advantage Special Needs Plans (SNPs), I am writing to offer ACAP’s policy recommendations for the D-SNP program. For the purposes of this letter we will be basing our comments on H.R. 3168, the “Special Needs Plans 3 Reauthorization Act of 2017” as passed by the Ways and Means Committee on July 13 of this year. On behalf of the Association for Community Affiliated Plans, the 60 Safety Net Health Plans, and the 20 million Americans served by them, we are grateful for the opportunity to explain the policy recommendations and to propose the corresponding legislative language.

Permanent Authorization of D-SNPs

Although we are pleased that H.R. 3168 provides for longer than a short-term reauthorization, ACAP strongly supports permanent authorization of D-SNPs. D-SNPs have been reauthorized numerous times, but only in a series of short-term extensions. The benefit of D-SNPs to enrollees is that they can tailor their care management, provider interventions, and partnerships with community-based organizations to the unique needs of their dual-eligible enrollees. We believe that the lack of permanent authorization destabilizes the program for beneficiaries, states, health plans, and providers. ACAP supports permanent authorization of D-SNPs because doing so would provide certainty to plans, beneficiaries, and states and would foster longer term partnerships and investments in care management and integration with Medicaid.

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